Objecting to the Settlement

If your financial institution is a Settlement Class Member, you can object to the Settlement if you do not think it is fair, reasonable, or adequate. You can give reasons why you think the Court should not approve it. The Court will consider your views. If you both object to the Settlement and seek to exclude your financial institution, your financial institution will be deemed to have excluded itself and your objection will be deemed null and void.

Your objection must be in writing, and must include:

  • The name of this Litigation: Arkansas Federal Credit Union and Summit Federal Credit Union v. Hudson’s Bay Company, et al., No. 19-cv-4492 (PKC) (S.D.N.Y.);
  • Your financial institution’s full name, and the full name, address, email address, and telephone number of the person acting on its behalf; and
  • All grounds for the objection stated with specificity.

Any objection must be either filed electronically with the Court or mailed to the Clerk of the Court, Class Counsel, and Hudson’s Bay counsel at the addresses set forth below. The objection must be electronically filed, or if mailed postmarked, no later than November 15, 2021.


Clerk of the Court
USDC, South District of New York
Daniel Patrick Moynihan
United States Courthouse 500 Pearl St.
New York, NY 10007-1312

Settlement Class Counsel

Joseph P. Guglielmo
230 Park Avenue, 17th Floor
New York, NY 10169

Defense Counsel

Gregory T. Parks
Morgan, Lewis, & Bockius LLP
1701 Market Street
Philadelphia, PA 19103